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Compliance Program, Referral Integrity, Marketing and Conflicts of Interest

Sets up the Agency's compliance program, forbids paying or receiving anything for referrals, bars inducements to patients, requires truthful marketing and admission only of eligible patients, controls conflicts of interest and gifts, explains how to report concerns without retaliation, and requires overpayments to be reported and returned.

Preview: full text with a package
About this policy
Policy number
NC-HSP-ETH-01
Version
1.0
Main rule
10A NCAC 13K .0210(a)
Library
North Carolina hospice · 60 policies
Category
Ethics
Sections
19

In short

  • Never offer, pay, ask for or accept anything of value for a referral.
  • Do not offer patients or families gifts or favors to choose us, and never pressure anyone to elect, stay on or leave hospice.
  • Do not accept money, gifts beyond a small token, loans or tips from patients or families.
  • Report any concern about fraud or wrongdoing to your supervisor or Pat Sample. You may report anonymously, and there is no retaliation.
  • Sign the compliance and conflict of interest attestation every year.

What's inside

19 sections. The full text comes with the One-time Policy Pack.

Full text with a package
  • Terms of Reference
  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Policy Statement (10A NCAC 13K .0210(a))
  • 5. The Compliance Program
  • 6. Hospice Risk Areas the Agency Audits
  • 7. Referral Sources
  • 8. Marketing, Admissions and Patient Inducements
  • 9. Conflicts of Interest and Gifts From Patients
  • 10. Reporting Concerns
  • 11. Overpayments
  • 12. Responsibilities
  • 13. Records and Compliance Monitoring
  • 14. Staff Training
  • 15. References
  • 16. Related Policies and Forms
  • 17. Approval
  • 18. Revision History

An inspector may ask

  • Who is your compliance officer, and how do staff report a concern?
  • How do you make sure marketing staff do not promise services or admit patients who are not eligible?

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